The Good, The Bad, and The Good, The Bad, and The Sticky:The Sticky:

Syrups and HoneySyrups and Honey

2012 Customs Brokers & Forwarders 2012 Customs Brokers & Forwarders Association SeminarAssociation Seminar

Commodity Team 776Commodity Team 776

Port of San FranciscoPort of San Francisco

Customs And Border ProtectionCustoms And Border Protection

OVERVIEWOVERVIEW Various Types of Syrups and Blends Various Types of Syrups and Blends

containing Fructose, Glucose and containing Fructose, Glucose and MaltoseMaltose

Scope/Latest Update on Honey and Scope/Latest Update on Honey and Syrup Blends from ChinaSyrup Blends from China

What information to ask from 1What information to ask from 1stst time time honey/syrup importershoney/syrup importers

Q & AQ & A

HeadingsHeadings 1702-Other sugars, including 1702-Other sugars, including

chemically pure lactose, maltose, chemically pure lactose, maltose, glucose and fructose, in solid form; glucose and fructose, in solid form; sugar syrups not containing added sugar syrups not containing added flavoring or coloring matter;flavoring or coloring matter;

1702.11-Lactose Syrup1702.11-Lactose Syrup

1702.20-Maple Syrup1702.20-Maple Syrup

Headings (cont.)Headings (cont.) 1702.30-Glucose Syrup (No Fructose 1702.30-Glucose Syrup (No Fructose

or contains <20% in dry state)or contains <20% in dry state) 1702.40-Glucose Syrup (Contains 20-1702.40-Glucose Syrup (Contains 20-

49% Fructose in dry state)49% Fructose in dry state) 1702.60-Fructose Syrup (>50% 1702.60-Fructose Syrup (>50%

Fructose)Fructose) 1702.90-Other1702.90-Other Most are subject Most are subject

to Quotato Quota

What about Brown Rice What about Brown Rice Syrups?Syrups? Brown Rice Syrup usually Brown Rice Syrup usually

contains maltose, which will contains maltose, which will put it under 1702.90.9000 as put it under 1702.90.9000 as “other sugar and sugar syrup “other sugar and sugar syrup blends: other”blends: other”

Important to ask the importer Important to ask the importer for ingredient list to for ingredient list to determine correct HTS code determine correct HTS code for the syrups.for the syrups.

Honey/Syrup BlendsHoney/Syrup Blends More than 50% natural honey--the More than 50% natural honey--the

blend should be classified as honey blend should be classified as honey (0409.00).(0409.00).

Less than 50% natural honey--the Less than 50% natural honey--the blend should be classified as syrups.blend should be classified as syrups.

HTS codes will be determined by % of HTS codes will be determined by % of fructose, glucose and maltose in the fructose, glucose and maltose in the syrups.syrups.

Importer must provide percentage of Importer must provide percentage of honey vs syrup to properly classify it.honey vs syrup to properly classify it.

Honey/Rice Syrup Blends Honey/Rice Syrup Blends from Chinafrom China

One of the ways for importers to One of the ways for importers to circumvent antidumping duties.circumvent antidumping duties.

The merchandise is either honey or The merchandise is either honey or have some honey drums mixed in with have some honey drums mixed in with syrup drums in the shipment (to be syrup drums in the shipment (to be blended later domestically).blended later domestically).

Previously subject to Antidumping Previously subject to Antidumping Duties (A570-863) if honey is >50%.Duties (A570-863) if honey is >50%.

SCOPE SUMMARY SCOPE SUMMARY UPDATEUPDATE

Effective June 21, 2012Effective June 21, 2012 FR V.77, No. 120FR V.77, No. 120 ALL honey/syrup blends from ALL honey/syrup blends from

China, China, regardlessregardless of the of the percentage of honeypercentage of honey they contain, they contain, are now within scope and subject are now within scope and subject to anti-dumping dutyto anti-dumping duty

of $2.63/kg.of $2.63/kg.

Things to ask from First Things to ask from First Time/Suspicious ImportersTime/Suspicious Importers

All documents/paperwork in All documents/paperwork in EnglishEnglish.. Process flowchart, Certificate of Process flowchart, Certificate of

Analysis, and Specification Sheet.Analysis, and Specification Sheet. Be extra careful with first time Be extra careful with first time

importers having large and/or multiple importers having large and/or multiple honey/syrup shipments within a short honey/syrup shipments within a short period of time.period of time.

CBP Requests and ActionsCBP Requests and Actions

Suspicious shipments will be sampled and Suspicious shipments will be sampled and tested.tested.

Single Entry Bond Requirements (usually at 3 Single Entry Bond Requirements (usually at 3 times the value) before shipment is released.times the value) before shipment is released.

Shipments Shipments will be re-exported if no SEB. be re-exported if no SEB. Purchase Orders and Proof of Payment.Purchase Orders and Proof of Payment. Beekeeper Records and Transportation Beekeeper Records and Transportation

Records.Records.

CBP Requests and Actions CBP Requests and Actions (cont.)(cont.)

Invoices for the containers (Drums, Barrels).Invoices for the containers (Drums, Barrels). Correspondences (emails, etc.) between Correspondences (emails, etc.) between

Seller and Buyer.Seller and Buyer. Domestic Buyer Information.Domestic Buyer Information. If the syrup contains honey with Chinese If the syrup contains honey with Chinese

origin, then importer must pay ADD in cash origin, then importer must pay ADD in cash before release or have it re-exported to before release or have it re-exported to original country of export.original country of export.

Questions?Questions?